TMI Blog2015 (12) TMI 95X X X X Extracts X X X X X X X X Extracts X X X X ..... ed by the DRP is not warranted. We direct the same to be deleted. Ground is allowed. Adjustment in respect of corporate guarantee extended - Held that:- There is a service rendered to AE by providing guarantees and therefore invoking provisions of TP does arise on the facts of the case. Considering case of M/s. Four Soft Ltd. [2011 (9) TMI 634 - ITAT HYDERABAD ] the adjustment made on the guarantee commission on the corporate guarantees provided by assessee to its AEs. However, as far as the rate at which the guarantee commission is to be considered, the adoption of 2% was not approved in various co-ordinate Bench decisions thus we direct the TPO to adopt 0.53% as the guarantee commission rate instead of 2% adopted by him Reducing the operating profits of the tax-payer company on account of income from settlement of patent infringement suit credited to Profit Loss account and foreign exchange fluctuations (Credit) - Held that:- We agree with the finding of the Assessing Officer as held by the DRP that the income from settlement of patent infringement cannot become part of operating revenues either on bulk drug manufacturing (API) segment or on product development service (P ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... into the public domain. Therefore, we are of the opinion that the matter should go back to TPO who should consider selecting proper comparables, after appropriate FAR analysis and by giving due opportunity to assessee, to re-consider the comparability analysis Non deducting from the returned income, corresponding to adjustment u/s. 92CA made by Transfer Pricing Officer in Astrix Laboratories Limited - Held that:- there is no dispute with reference to the receipt of these amounts, one as an income i.e., management fee of ₹ 1.12 crores and other being the reimbursement of expenses of ₹ 1.05 crores. As far as the reimbursement of expenditure is concerned, we have already directed in the earlier ground to consider the nature of amount and exclude from the computation for the purpose of transfer pricing on verification. Therefore, to that extent, the claim will be a double claim. With reference to the management fee, we are not sure why there is an adjustment in another domestic transaction, if contentions of assessee are correct. If transaction is between two domestic companies transfer pricing regulations does not apply in the impugned year. If one domestic company pai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t assessee has deducted tax at the time of making contribution to the fund and has treated it as part of salary of the concerned directors. That being the case, the expenditure incurred should be allowed as a deduction. Allowance of Employee Stock Option Scheme - Held that:- We restore this issue to the file of the Assessing Officer to examine the claim afresh in the light of decision of the Hon'ble Special Bench of the ITAT Bangalore in the case of M/s. Biocon (2014 (12) TMI 838 - ITAT BANGALORE). Rejection of basis for apportionment of common corporate overhead expense to all the units of the company including 100% Export Oriented undertakings eligible for deduction u/s. 10B and in the process reducing the benefit u/s. 10B - Held that:- Allocation of expenditure as was done by the assessee is more rationale and is in tune with the principles laid down by the Institute of Cost Accountants and also for the purpose of Company Law. Therefore, considering the detailed objections raised by the assessee as placed in the objections to the DRP, we are of the opinion that the allocation by the assessee is to be upheld. Assessing Officer is directed to accept the assessee's al ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as already ordered the depreciation to be allowed in assessment year 2002- 2003, consequently, depreciation has to be allowed on WDV in this year. He is empowered to take rectification proceedings in case that order was not upheld by the Hon'ble High Court. In view of this, to that extent of claim of depreciation amounting to on brought forward written down value, Assessing Officer is directed to allow the depreciation after verifying the WDV figures. LTCG or STCG - difference between the market value for the purposes of levy of stamp duty while registering the sale deed and actual sale consideration per sale agreements for sale of Petbasheerbad land - Held that:- The capital gain is attracted the moment the property was handed over, the sale consideration was also received. So the capital gain is correctly offered by assessee in AY. 2006-07 itself.Provisions of Section 50C can be invoked but what AO did was to bringing to tax only the difference in SRO price and Sale Price to tax. He is bound to calculate the capital gains. He did not bring the capital gain offered in AY. 2006-07 to this year. There cannot be computation of capital gains in two assessment years on sale of o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... KOTAIAH, ACCOUNTANT MEMBER AND SHRI SAKTIJIT DEY, JUDICIAL MEMBER For The Assessee : Shri Raghunathan Sampath, AR For The Revenue : Shri T. Venkata Reddy, CIT-DR ORDER PER B. RAMAKOTAIAH, A.M. : This appeal by assessee is against the orders of Assessing Officer (AO) u/s. 143(3) r.w.s. 144C of the Income Tax Act [Act] consequent to the directions issued by Dispute Resolution Panel [DRP], Hyderabad dated 26-09-2011. 2. Assessee is in the business of manufacture of pharmaceutical products, mainly Active Pharma Ingredients (in short API ). During the year, assessee filed return of income declaring total loss of ₹ 40,04,39,585/- under the normal provisions of the IT Act and book profit/loss of Rs. (-) 5,17,28,098/- u/s. 115JB of the Act. This return was accepted u/s. 143(1) and a notice u/s. 143(2) was issued. During the course of proceedings, assessee has revised certain claims. Since assessee transacted with its Associated Enterprise [AE] as defined in Section 92A of the Act, the matter was referred to Transfer Pricing Officer [TPO], who issued an order u/s. 92CA of the Act dt. 31-03-2010. The AO framed draft assessment order dt. 31-12-2010 taking in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... VVF Ltd., Vs. DCIT alternatively, it contended that ABN Amro Bank provided loans with an interest rate of EURIBOR + 60-125bps for Tranche A and EURIBOR + 129bps for Tranche B. Therefore, the relevant period interest would be 3.35% and the same can be restricted to the above. On the reason that earlier year s issues are pending before the ITAT, the DRP did not interfere. 5.1 Ld. Counsel fairly admitted that ITAT has held adjustments at LIBOR + 2% / EURIBOR + 2% in the later year. It was submitted that assessee has no objection if the same rate is adopted. It was further submitted that DRP accepted in AY. 2006-07 at EURIBOR + 2%. Considering the orders of the DRP in AY. 2006-07 and also order of ITAT in AY. 2008-09 in ITA No. 665/Hyd/2013 in assessee's own case on the issue of adjustment towards interest and advance provided to AEs, we direct the AO/TPO to adopt EURIBOR + 2% rate of interest for making the adjustment under the provisions. The ground is accordingly considered allowed. Ground No. 3: The Dispute Resolution Panel erred in confirming the Transfer Pricing Officer's order under sec. 92CA of the Act, for making an adjustment of ₹ 8,04,750/- as inter ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , we are of the opinion that TPO cannot reclssify the amount as 'loans and advances'. Moreover, we have considered the appeal in AY. 2008-09 vide orders dt. 10-01-2014, wherein it is noticed that TPO has not made any adjustment from 1st April 2007 to the period of allotment. Therefore, keeping that factor also in mind, we are of the opinion that adjustment proposed by the TPO as confirmed by the DRP is not warranted. We direct the same to be deleted. Ground is allowed. Ground No. 4: The Dispute Resolution Panel erred in confirming the Transfer Pricing Officer's order under sec. 92CA of the Act, for making an adjustment of ₹ 19,11,68,600/- in respect of corporate guarantee extended to Matrix Laboratories NV, Belgium a wholly owned subsidiary of the tax-payer. Ground No. 5: The Dispute Resolution Panel erred in confirming the Transfer Pricing Officer's order under sec. 92CA of the Act, for making an adjustment of ₹ 60,81,800/- in respect of corporate guarantee extended to Mchem Pharma Group Ltd., China a subsidiary company of the tax-payer. 7. Briefly stated, in order to acquire entry into European markets, assessee floated 100% owned c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n Limited (previously known as Semantic Space Technologies Ltd) in ITA No. 237/Hyd/2014 dt. 31-12-2014 directed the TPO to adopt the rate of 0.53%, which is considered as arm's length in other cases also. Respectfully following the same, we direct the TPO to adopt 0.53% as the guarantee commission rate instead of 2% adopted by him. Therefore, these grounds are partly allowed accordingly. Ground No. 6: The Dispute Resolution Panel erred in confirming the Transfer Pricing Officer's order under sec. 92CA of the Act, for reducing the operating profits of the tax-payer company by ₹ 36,40,74,254/- on account of (i) income from settlement of patent infringement suit credited to Profit Loss account of ₹ 26,83,94,695/- and (ii) foreign exchange fluctuations (Credit) of ₹ 9,56,79,559/- 8. As seen from the above ground, there are two issues to be considered. Ground No. 6(i) is on the issue of income from settlement of patent infringement suit credited to P L A/c of ₹ 26,83,94,695/-. This issue was considered by the co-ordinate Bench in the later year in assessee's own case for AY. 2008-09 and Ld. Counsel fairly admitted the issue was held agains ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... There is no dispute as the amount was offered as revenue income. There is also no dispute that the amount offered in the P L account was adjusted in the computation of income for the year as the same is already taxed in the earlier year. We are not considering either taxability of the amount or the allowability of the amount as a deduction/ expenditure. The issue pertains to the transfer pricing adjustments which operate under different mechanism. While arriving at the profits of an organization, the operating profits over the operating cost is considered as a basic principle to arrive at operating profits in an assessee's case. As discussed in the later part of the order, there are two segments of income and different segments of profit source and different comparisons are required. While arriving at segmental profits, only those incomes pertains to that segment and cost pertain to that segment are allocated so as to arrive at the operational profits for comparison purposes. This exercise has nothing to do with the principles laid down under section 37(1) or the principles on patent infringement compensation. The simple issue to be examined is, whether the income accounted b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ucts. The DRP upheld the action of TPO in removing foreign exchange gains and losses from the operating results as an objective one. Assessee is aggrieved. 8.3 It was submitted that foreign exchange gain and foreign exchange loss should not be excluded while computing the margin of assessee as well as comparable companies as the same are arising during the normal course of business of assessee. Ld. AR relied on the decision of M/s. Four Soft Ltd., in ITA No. 1495/Hyd/2010 [44 Taxman.com 479] (supra), M/s. Capital IQ Information Systems (India) Pvt. Ltd., Vs. DCIT in ITA No. 1961/Hyd/2011 dt. 23-11-2012 [32 Taxman.com 21 (Hyd)] and Brigade Global Services [33 Taxman.com 618]. 8.4 Ld. DR on the other hand supported the order of lower authorities. 8.5 We have considered the submissions of the parties in this regard. This issue was already decided in favour of assessee holding that foreign exchange fluctuation gain/loss are part of operating margin of assessee as well as comparable companies while undertaking ALP adjustments. The co-ordinate Bench in the case of M/s. Capital IQ Information Systems (India) Pvt. Ltd., Vs. DCIT in ITA No. 1961/Hyd/2011 dt. 23-11-2012 (supra), has ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the comparable company . 8.6 In view of the above, we direct the TPO to consider the foreign exchange gain or loss as part of operating profits of assesseecompany. similarly, he is also directed to consider the foreign exchange gain or loss as part of operating profits of comparable companies also while working out the ALP while doing TP adjustments. Ground is considered allowed accordingly. Ground No. 7: The Dispute Resolution Panel erred in not directing the deletion of adjustment of ₹ 16,50,00,000/- u/s. 92CA of the Act in respect of sales to Associated Enterprises and determining the Arms-length price of Profit Level Indicator being operating profit margin at 27.34% (operating profit/cost) and 20.48% (operating profit/operating revenue) by rejecting the basis adopted by the taxpayer u/s. 92 of the Act. 9. During the financial year 2006-07, the assessee company sold finished goods to the tune of ₹ 74.81 Crores to Matrix Labs Inc, USA, ₹ 6.04 Crores to Mylan Pharmaceuticals Inc, USA and ₹ 1.02 Crores to Xiamen Mchem Pharma, China aggregating to ₹ 81.87 Crores. The company also purchased raw materials to the tune of ₹ 35.88 Cro ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd drug formulations . He arrived at about 11 companies and issued show cause notice to assessee why they cannot be selected for comparison of ALP. Assessee made detailed objections with reference to the fresh selection of comparables. Thereafter, the TPO restricted the comparison to only two companies M/s. Divi s Labs Ltd., and M/s. Biocon Limited accepting objections with reference to other companies. Assessee filed objections vide para 5(b) of the objections before the DRP. However, DRP was silent on the issue and has not adjudicated the objections raised by assessee. 9.5 Ld. Counsel submitted that assessee is in the business of active pharmaceuticals ingredients which are generally called bulk drugs and was not involved in formulations at all. He referred to the DRP s order particularly the finding given in Ground No. 7 that assesseecompany is engaged in manufacture and sale of APIs and about to commence the business of formulations . He submitted that the business of formulations has not started during the year and only few samples were manufactured and assessee s entire business activity during the year involved only manufacturing bulk drugs. Therefore, TPO s observation ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in deciding the issue one way or the other. Since the objections are not examined by the DRP, we are of the opinion that that selection of comparables should be restored to the authorities. As can be seen from the objections raised, assessee objected selection of these two companies as comparables. This require re-examination by the TPO, as more data would have come by this time into the public domain. Therefore, we are of the opinion that the matter should go back to TPO who should consider selecting proper comparables, after appropriate FAR analysis and by giving due opportunity to assessee, to re-consider the comparability analysis. In case assessee has still objections on the proposal of the TPO, then DRP should examine the objections and decide the issue by giving proper reasons. With these observations, the issue involved in this ground is restored to the file of TPO, by setting aside the order of TPO/AO to that extent. Ground No. 8: The Dispute Resolution Panel erred in confirming Assessing Officer's action in not deducting ₹ 3,31,40,155/- from the returned income, corresponding to adjustment u/s. 92CA of the Act, made by Transfer Pricing Officer in Astrix ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... fer pricing on verification. Therefore, to that extent, the claim will be a double claim. With reference to the management fee, we are not sure why there is an adjustment in another domestic transaction, if contentions of assessee are correct. If transaction is between two domestic companies transfer pricing regulations does not apply in the impugned year. If one domestic company paid to its AE and assessee receives from AE, the transactions are different in nature. Whether the same can be allowed in the hands of other domestic company or not has no bearing in the assessee's hands as the said amount was received and was accepted by the assessee to be taxed. We approve the DRP observation that taxability or otherwise of the amount in one hand does not affect the adjustment in other hand unless it is provided so in the Act. Therefore, this ground of the assessee is rejected . 10.2 Respectfully following the same, we reject the grounds raised by assessee. Ground No. 9: The Dispute Resolution Panel erred in failing to direct Assessing Officer to allow the deduction of ₹ 80,31,79,402/- claimed u/s. 10B of the Act in respect of Export Oriented Undertakings situated ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... atuity Act. 12. Briefly the facts relating to this issue are, during the assessment proceeding, AO noticed that assessee has claimed deduction on account of contribution made to superannuation fund and gratuity fund for income specified for some specified directors. In the note submitted to the return of income, assessee stated that the contribution made was subjected to TDS by including the same as part of salary of the specified directors. It was submitted, the expenditure incurred being wholly and exclusively for the purpose of business, it is to be allowed u/s 37 of the Act. In support of such contention, assessee relied on the following decisions: 1. CIT Vs. Western India Paper and Board Mills Pvt. Ltd., 189 ITR 309 (Bom.); and 2. CIT Vs. Punjab Financial Corporation Ltd., 295 ITR 510 (P H) 12.1 AO however did not accept the contention of assessee. He was of the view that contribution to superannuation fund/ gratuity fund can only be claimed as deduction as per the provisions of section 36(1)(iv) and not u/s 37, which is a residuary provision. Accordingly, he disallowed the claim of deduction. Though the assessee objected to such disallowance before DRP, but, the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he expenditure incurred should be allowed as a deduction. In this regard, we rely on CIT Vs. Punjab Financial Corporation Ltd., [295 ITR 510] (supra). Similar view was also taken in later year in assessee s own case. Accordingly, we delete the addition made by the AO. Ground No. 12: The Dispute Resolution Panel erred in confirming the Assessing Officer to allow a sum of ₹ 5,46,85,050/- being amount debited to Profit Loss account in respect of Employee Stock Option Scheme. 13. The assessee formulated employee stock option plan for granting certain stock options to its employees/Directors. This amount has been charged as a personnel cost and has been accounted in line with the guidance note issued by the Institute of Chartered Accountants of India. The Assessing Officer held that the expenditure is not revenue and is contingent and notional in nature. This issue was considered in earlier year also and the DRP following the same rejected the objection. It was submitted that the issue of ESOP was decided by the Hon'ble Special Bench of the ITAT Bangalore in the case of M/s. Biocon Limited vs. DCIT (LTU) Bangalore vide ITA.368 to 371/Bang/2010 etc., dated 16- 07 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ervice is rendered for one year, it becomes obligatory on the part of the company to honor its commitment of allowing the vesting of 25% of the option. The liability is incurred at the end of the first year though it is discharged at the end of the fourth year when the options are exercised by the employees. The fact that some options ITA.No.66/Hyd/2013 Mylan Laboratories Ltd. (Formerly Matrix Laboratories Ltd.) may lapse due to non-exercise/ resignation etc does not make the entire liability contingent; (iii) However, the obligation to issue shares at a discounted premium does not arise at the stage the options are granted. It arises at the stage that the options are vested in the employees. The amount deductible has to be determined based on the period and percentage of vesting under the ESOP scheme; (iv) There is likely to be a difference in the quantum of discount at the stage of vesting of the stock options (when the deduction is allowable) and at the stage of exercise of the options. The difference has to be adjusted by making suitable northwards or southwards adjustment at the time of exercise of the option depending on the market price of the shares then prevail ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... was pending in the earlier year, the learned DRP did not intervene with the issue. 14.1 It was submitted that Assessee has identified the corporate overheads on the basis of accepted cost accounting principles and also guidance note with reference to company law. It was submitted that the indirect manufacturing expenses are distributed over operating divisions on the basis of gross material cost and personal costs are distributed over operating divisions on the basis of staff strength in each operating division and selling administrative cost distributed over operating divisions on the basis of sales affected. It was contended that this allocation is consistent with the assessee's allocation in earlier years and also in tune with the principles laid down under the cost accounting principles as well as guidance note issued by the Ministry of Company Affairs in the area of indirect tax. The learned Counsel relied on the decision of ITA.No.66/Hyd/2013 assesses own case and Hon'ble Delhi High Court in the case of S.T. Micro Electronics Pvt. Ltd. in ITA.No.928/2010 wherein the Hon'ble High Court upheld the ITAT order and in turn of the Ld. CIT(A) order wherein the bifurca ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ted deduction at 150% of ₹ 2,26,00,589/- U/s. 35(2AB) of the Act in respect of clinical drug trials carried out by it on the ground that it is incurred outside the in-house R D . 15. This ground is relating to assessee s claim for weighted deduction U/s. 35(2AB) of 150% of an amount of ₹ 2,26,00,589/-. Ld. Counsel for assessee referred to form 3CL to point out that such expenditure was eligible for weighted deduction. He has contended that assessee is therefore is claiming weighted deduction only to the extent of certification in respect of clinical trials carried out by it. He referred to the order of the co-ordinate Bench in assessee s own case in AY. 2009- 10 in ITA No. 611/Hyd/2014 dt. 10-12-2014 to submit that the matter was referred to the AO for necessary examination. The order of coordinate Bench vide para 12 is as under: 12. When the learned counsel for the assessee was required by the Bench to clarify as to how the claim of the assessee is covered by the above Explanation, he has contended that the expenditure in question is incurred by the assessee for filing application for patent rights under patents Act, 1970. He has also submitted that the asse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is holding an amount of 2% to 10% on the exempt income as reasonable amount in the year prior to application of Rule 8D. Accordingly, we are of the opinion that an amount of ₹ 1,00,000/- can be considered as a reasonable amount incurred for earning the exempt income, considering that assessee has made investments and require personnel to monitor the same. For the same. AO is directed to disallow an amount of ₹ 1,00,000/- under the provisions of Section 14A. Ground is partly allowed. Ground No. 16: The Dispute Resolution Panel erred in confirming the Assessing Officer s order in not allowing a) Depreciation @ 12.5% being 50% of normal depreciation amounting to ₹ 5,00,000/- in respect of non-compete fee of ₹ 40,00,000/- paid in relation to Concord Biotech Limited during the year b) Depreciation @ 25% amounting to ₹ 11,86,523/- on brought forward written down value of ₹ 47,46,094/- in respect of Noncompete fee of ₹ 200 lakhs paid to Medispan Ltd., by Medicorp Technologies Ltd., (amalgamating company) in the previous year relevant to Asst. Year 2002-03. 17. This ground is against the claim of depreciation on differe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ers i.e., Mr. Sudhir Vaid in the present assessment year i.e., 2007-08. 17.2 Before the Assessing Officer and DRP, the assessee relied on the decision of the CIT vs. Medicorp Technologies India Ltd. which was upheld by the ITAT, Chennai Bench (supra). The learned Assessing Officer relying on the decisions of the ITAT, Chennai Bench in the case of AB Mourya Pvt. Ltd. in ITA.No.1293/2006 dated 23-11-2007 and Guruji Entertainment Net Work Ltd. reported in 14 SOT 556 (Del.); M.M. Nissim Co. vs. ACIT (2007) 18 SOT 274 (Mum.) and Motor Surveyors Pvt. Ltd. vs. ITO 32 SOT 268 (Chennai) rejected the claim of the assessee and DRP upheld the order of the AO. 17.3 Ld. Counsel submitted that the issue is decided by the Coordinate Bench in assessee's own case, accordingly. This issue was in later year in ITA No. 66/Hyd/2013 (supra) wherein the claim was examined as if that was the first year of claim and held against. The order is as under: After considering the rival submissions, we are of the opinion that the cases against the assessee are more in number and there is a consistent view of the ITAT in not allowing the depreciation on non-compete fee. This issue which was origina ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g any employment. This cannot be considered under section 32(1) as an intangible asset . 17.4 Accordingly, the claim of depreciation on the item (a) is not allowed and to that extent ground is rejected. In the result, ground is partly allowed. Ground No. 17: The Dispute Resolution Panel erred in confirming the order of the Assessing Officer by holding that the difference of ₹ 8,55,50,902/- between the market value for the purposes of levy of stamp duty while registering the sale deed on 24.08.2006 and actual sale consideration per sale agreements dated 30.09.2005 for sale of Petbasheerbad land as short term capital gain by ignoring the fact that a) The market value for levy of stamp duty on the date of transfer on 30.09.2005 (being the date of handing over possession of the property) is lower than sale consideration, and b) Profit of ₹ 1,52,66,486/- (sale price ₹ 7,77,99,098/-, less cost ₹ 6,25,32,612) from sale of the said land was already offered as short term capital gain in Assessment Year 2006-07 based on the date of handing over of the possession of the property to the buyer. Ground No. 18: Without prejudice to ground ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ain. (d) DRP did not interfere with the order on the reason that proceedings for AY. 2006-07 were pending. The order of AO in the reassessment proceedings indicate that AO did not reduce the capital gains offered in this year. This indicates that the action of assessee in offering Short Term Capital Gain was accepted. (e) Even though, the provisions of Section 50C was amended to clarify that the SRO value as on date of agreement of sale has to be considered that need not be considered here as AO on facts accepted capital gain in AY. 2006-07 itself. 18.3 For the reasons stated above, the action of AO in bringing to tax the difference alone cannot be approved. Accordingly, the addition made is set aside. Grounds are allowed. Ground No. 19: The Dispute Resolution Panel erred in confirming the Assessing Officer s order in restricting the deduction under clause (II) of Explanation to Section 115JB of the Act in respect of export profits from the 100% export oriented undertaking eligible for deduction under sec. 10B of the Act, to the amount arrived at under normal computation instead of basing it on book profits and in the process increasing the book profits. 19. B ..... X X X X Extracts X X X X X X X X Extracts X X X X
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